Bradburn et al v. North Central Regional Library District

Filing 66

DECLARATION by Celeste Mountain Monroe in Support re 28 MOTION for Summary Judgment filed by North Central Regional Library District. (Attachments: # 1 Exhibit Pages 4-39)(Adams, Thomas)

Bradburn et al v. North Central Regional Library District

Doc. 66 Att. 1

Exhibit A
Dee!. of Celeste Monroe
Page 4

Dockets.Justia.com

,(

1 Thomas D. Adams, WSBA #18470

tom.adams~bullvant.eom
2 Bullvant Houser Bailey PC

TI HONORABLE EDWAR F. SHEA

1601 Fifth Avenue, Suite 2300 3 Seattle, Washington 98101-1618
Telephone: [phone]
4 Facsimile: 206.386.5130
5 Attorneys for Defendant North Central

Regional Librar Distriet
6

7
8

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IN THE UNTED STATES DISTRICT COURT EASTERN DISTRCT OF WASHIGTON
AT

SPOKA

SAR BRADBURN, PEAR 11 CHERRGTON, CHAES HEINEN,
and the SECOND AMNDMET 12 FOUNATION ,

No.: CV-06-327-EFS

13 Plaintiffs,
14

DEFENDANT NORTH CENTRAL REGIONAL LIBRARY DISTRICT'S INITIAL DISCLOSURES

v.

15 NORTH CENTRA REGIONAL LIBRAY
16 17
18

DISTRICT,
Defendant.

19
20 Rules of

Defendant Nort Central Regional Librar Distriet ("NCRL") pursuant to the Federal
Civil Procedure 26(a) state as follows:
Disclosure of

21 A.

Individuals Pursuant to FRCP 26(a)(1)(A)

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23

i.

Dean Marney, Director ofNCRL
c/o Bullvant Houser Bailey, PC
1601 5th Ave, Suite 2300 Seattle, WA 98101 [phone]

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25

Decl. of Celeste Monroe
Page 5

Mr. Marney is the Direetor of the NCRL. The Board ofDireetors appointed 26 Mr. Marney to his position in 1990. Mr. Marey played a eentral role in the development of

Page i BullvantlHouserlBailey PC
1601 Fifth Avecue. Suite 2300
Se.nle, Washington 98 J 0 J - J 618

Telephone: [phone]

I

5.

2
3

Sue DeWitz NCRL Finance Manager c/o Bullvant Houser Bailey, PC 1601 5th Ave, Suite 2300
Seattle, W A 98101

4

[phone]

5 Ms. DeWitz is the Finance Manager for NCRL. She was hired by Mr. Marey in
2004. Ms. DeWitz handles all of

6 knowledgeable with respect to the federal fuds, and other grants, that NCRL receives. She
7 did not playa role in the development ofNCRL's Internet Usage Policy or in the seleetion of any of the Internet filters. Ms. DeWitz also took minutes at monthly Board of Trustees
8 meetings.

the finances for the municipal corporation. She is

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10

6.

NCRL Board of Directors

At this time, it is not known whether any of members of the board will have this case. If, as discovery progresses, NCRL 11 information necessar for the defense of believes that it wil need to consult with any of these individuals, it wil amend this 12 disclosure.
13

7. NCRL Branch Librarians
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At this time, it is not known whether any ofNCRL's 31 branch librarians wil have this case. If, as diseovery progresses, NCRL these individuals, it wil amend this 16 believes that it wil need to consult with any of disclosure.
15
infonnation necessar for the defense of

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8.

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20
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Jan Walsh Washington State Librarian Point Plaza East 6880 Capitol Blvd
Tumwater, W A

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PO BOX 42460 Olympia, W A 98504-2460 [phone]
Jan Walsh is the Washington State Librarian. Ms. Walsh, and representatives of

her 24 office, have communicated with NCRL regarding the distriets eligibility to receive federal ard state funding, as well about NCRL's eompliance with the Children's Internet Proteetion

26 Page 6
25 A

et. Decl. of Celeste Monroe
Page 3 BullvantlHouserlBailey PC
1601 Fifth Avenue, Suite 2300 Seahle, Washington 9810).1618 Telephone: [phone]